Privacy Policy

Shimano Canada Ltd.

Updated^:April 30, 2026

Shimano Canada Ltd. (“Shimano,” “us,” “we” or “our”) is committed to maintaining the confidentiality of the Personal Information or our customers, employees, and Website visitors. This Privacy Policy (together with our Terms of Use and any other policies referenced in this Privacy Policy) identifies how we will collect and handle any Personal Information that we collect from you, or that you provide to us. By using the Website, you agree to this Privacy Policy. Whenever you submit information via the Website, you consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy.

If you are a resident of United States, the European Economic Area (“EEA”), the United Kingdom (“UK”) or Switzerland, this Privacy Policy also outlines additional policies applicable to our collection and processing of your Personal Information, which can be found here. Non-EEA countries do not have the same data protection laws as the United Kingdom, Switzerland and EEA. We will, however, take steps to ensure that any transfer of Personal Information will be secure and complies with applicable data protection laws.

As our Services evolve and we perceive the need or desirability of using your Personal Information collected in other ways, we may from time to time amend this Privacy Policy. The effective date appears at the end of this Privacy Policy. We encourage you to check our Site frequently to review the current Privacy Policy in effect and any changes that may have been made to it.

This Privacy Policy may be made available in both English and French. If this Privacy Policy is made available in French, both language versions shall be equally authoritative. In the event of any inconsistency between the English and French versions, the English version shall prevail to the extent permitted by applicable law. Where applicable law requires that these Terms or any portion thereof be provided in French, the French version shall be provided upon request.

Introduction

What Personal Information does Shimano Collect?

How does Shimano use Personal Information?

Do We Disclose Your Personal Information to any Third Parties?

How we Store your Personal Information

Access to other

SMS Terms and Conditions

Your Privacy Rights and Choices

Privacy Notice for United States Residents

Policies for Residents of EEA, UK and Switzerland

Retention of Personal Information

Conditions of use and changes to our privacy policy

Contacting us

1. Introduction

This Privacy Policy describes how Shimano collects, uses, and shares Personal Information of our customers, prospective employees, visitors to our website at http://fishshop.shimano.com (“Website”) and individuals who contact us to purchase goods and to request information. The Website and our other programs and services are referred to in this Privacy Policy as the “Services.” This Privacy Policy describes how we collect and use Personal Information (information which can be used to identify a specific individual) and anonymous data (which cannot be used to identify a specific individual).

Notice at Collection. Every time we ask you to provide Personal Information, we are collecting information that is subject to this Privacy Policy.

Region specific provisions. Certain provisions of this Privacy Policy, which are clearly labelled, apply only to users who are citizens or residents of particular regions (e.g., the EU or the United States). Otherwise, this Privacy Policy applies to all users of our Services, regardless of location.

Children. Our Services are not directed to children. See Protecting Children’s Privacy below.

2. What Personal Information does Shimano Collect?

2.1 Personal Information. For purposes of this Privacy Policy, “Personal Information” means information (whether stored electronically or in paper-based filing systems) relating to a living individual who can be identified from that data (or from that data and other information in our possession).

Shimano collects only that Personal Information that is relevant for the purposes for which the data is requested. Shimano does not use your Personal Information in any way that is incompatible with the purposes for which it was collected or for which you have consented. We collect the following Personal Information to provide you our Services:

Some of the categories of Personal Information include “Sensitive Personal Information,” and Shimano may collect and maintain your Sensitive Personal Information, which includes the following (if the information is not publicly available):

• Profile and Contact Information: We receive contact or other account profile information when you sign up for or interact with our Services, which may include your name, shipping address, email address, profile picture, or other information you choose to provide us.

• Device Information: We receive information about the computers, phones, and other devices you use to interact with us, including IP address (which may be used to determine general location), device identifiers, cookie IDs, the browser you use, your network connection, or other unique identifiers or device information.

• Payment Information: We may receive payment information when you make a purchase, such as your payment card number and expiration date.

• Use of Services: We receive information regarding your use of, or interactions with, our Services when you visit our Site and purchase goods and Services form us, from the products you view and purchase, the product reviews and ratings you post and share, your order history, your search queries, and other activities related to our Services.

• Settings and Privacy Preferences: We receive information about your settings and preferences, as well as information about your browser and device privacy settings.

• Communications with Us: We receive information, including message and email content, when you communicate with us (such as for customer support inquiries, taking surveys, participating in promotions or research).

• Social Network Accounts: If you choose to link, connect, or login to our Site through a third-party online service, you direct the service to send us certain information about you controlled by that service, such as profile information. This sharing is subject to the applicable privacy notices and your privacy settings of that service.

• Email and Shopping Service Integrations: We receive information from email messages in the inboxes that you connect to our Services.

2.2 Personal Information Collected about Customers

To provide our customers with individualized Services, we collect certain non-public, Personal Information about you from documents you provide to us. We will only obtain such information from third parties with your express consent and as permitted by law.

2.3 Personal Information Collected about Website Visitors or Callers

We may collect Personal Information from visitors to our Website and others who contact us to request information. In addition, our web server automatically collects and stores the following information from visitors to our Website:

• We collect information from web browsers, mobile devices, and servers, including browser type, IP address, unique device identifiers, language preference, referring website, date and time of access, operating system and mobile network information.

• We may also determine the approximate location of your device from your IP address. We collect and use this information to determine statistics about our Website, including how many people visit our Website from certain geographic regions.

2.4 Cookies, Beacons, Pixels and other Tracking Devices. Our Website uses cookies and pixel tags to collect this information, including Google Analytics cookies.

• Cookies store small amounts of data on your computer when you visit a website. Cookies assist us in tracking which of our features you like best. Therefore, cookies enable us to customize our content according to your preferences. You can accept or decline cookies by modifying your browser settings. You can block our use of cookies through settings in your browser. Because these settings are different in different browsers, we recommend that you visit All About Cookies at www.allaboutcookies.org, where you can find comprehensive information on cookie management and blocking for a wide variety of browsers.

• Some of our web pages may contain electronic images known as web beacons, which are also called “single-pixel gifs.” These images allow us to count users who have visited those pages and to deliver co-branded services. We may also include web beacons in promotional e-mail messages or newsletters to count how many messages have been opened and acted upon. Web beacons are not used to access your Personal Information, but they are a technique we use to compile aggregated statistics about usage on the Website. Web beacons collect only a limited range of information including the time and date of page view, cookie number and description of the page on which the web beacon resides.

• Advertisements appearing on our Website may be delivered to users by us or one of our advertising partners. Our advertising partners may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement. In this way, ad servers may compile information about where you, or others who are using your computer, saw their advertisements and determine which ads are clicked on. This information allows an ad network to deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by Shimano only and does not cover the use of cookies by any advertisers.

We do not collect any other categories of information from our Website visitors or individuals who contact us to request information.

3. How does Shimano use Personal Information?

3.1 Consent. We will only collect, use and disclose your Personal Information with your consent unless otherwise allowed by law. Your consent may be given expressly or implied, depending on the circumstances and the sensitivity of the information. You will be asked to consent expressly to any collection of Personal Information about you that is particularly sensitive, such as information about your financial information or your body measurements. In other cases, your consent is implied, such as when you respond to a customer satisfaction survey or speak with our representatives after having been notified that the call may be recorded.

3.2 Cross-jurisdictional Transfers. By providing us with Personal Information, you acknowledge and agree that your Personal Information may be transferred or disclosed to other jurisdictions for processing and storage, including countries in which Shimano is represented by affiliates, branches or other offices. These other jurisdictions may have laws regarding the protection of Personal Information which are less stringent than the laws in your jurisdiction. Furthermore, we may disclose your Personal Information in these jurisdictions in response to legal process or where we believe in good faith that disclosure is required by law.

Residents of Quebec: In accordance with Quebec private sector privacy legislation, Shimano assesses personal information that is being transferred outside of Quebec to ensure that the information receives adequate protection. As a company with operations across Canada, Shimano and its family of companies may transfer your information outside of Quebec to better serve you as a customer.

3.3 Personal Information Collected about Customers

We will use this information:

• to provide you with the Services that you request from us;

• to carry out our obligations arising from any contracts between you and us or any affiliated companies or third-party vendors;

• to contact you in the future to provide you with information about other products and Services we offer, or that are offered by our affiliates or third-party vendors;

• to notify you about changes to our Services;

• to comply with applicable laws and regulations.

3.4 Personal Information Collected about Website Visitors or Callers

We will use this information:

• to provide information you requested about our Services;

• to improve our Website to ensure that content is presented in the most effective manner for you and for your computer;

• as part of our efforts to keep our Website safe and secure.

4. Do We Disclose Your Personal Information to any Third Parties?

4.1 Personal Information Collected about Customers

Shimano does not sell your Personal Information to any third parties or share your Personal Information to facilitate advertising goods or services by others.

Shimano may share your information with service providers and contractors to provide the Services. When we do, we enter into a written agreement requiring that party to comply with all applicable laws and restricting that party from: selling or sharing Personal Information; using the Personal Information for any purpose other than the purpose specified the agreement; using, retaining or disclosing the Personal Information other than as specified in the agreement; or combining the Personal Information with Personal Information the service provider or contractor receives or collects in other contexts. There are times when a service provider or contractor may engage another party to assists in providing the Services; in those cases, the service provider or contractor must notify us in advance, and must have an agreement restricting the use, sale and sharing of the Personal Information that is similar to our agreement with our service provider or contractor.

By using our Services and providing your Personal Information, you agree that we have the right to disclose the categories of Personal Information we collect, as identified in Section ‎2 with our service providers for the following business purposes identified in Section ‎3.

There are other circumstances when we may share your Personal Information:

• Merger or Sale – We may share information in conjunction with a prospective purchase, sale, or merger of all or part of our practice, provided that we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective purchaser does not disclose information obtained during the review. If we sell all or a part of our business or assets, or merge with another company, we will disclose Personal Information to the purchaser as part of the transaction.

• Legal Proceedings – We may share Personal Information in connection with actual or threatened legal proceedings or alternative dispute resolution proceedings, either initiated by or against us, provided we disclose only the information necessary to file, pursue, or defend against the lawsuit, and take reasonable precautions to ensure that the information disclosed does not become a matter of public record.

• Legal Obligations – If we are under a duty to disclose your Personal Information in order to comply with any legal obligation, or any lawful request by public authorities (including to meet national security or law enforcement requirements), or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of us, our customers, or others.

4.2 Personal Information Collected about Website Visitors or Callers

We do not disclose to any third parties Personal Information collected from Website visitors or callers seeking additional information about our Services.

5. How we Store your Personal Information

Shimano uses reasonable and appropriate measures to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing undertaken and the nature of the Personal Information we collect.

We will keep your Personal Information for as long as we need it, or as otherwise prescribed by law, for the purposes set out above. This period will vary depending on your interactions with us. You may contact us for a copy of our standard record retention policy, including the retention period for different types of information. We may also keep a record of correspondence with you (for example if you have made a complaint about our Services) for as long as is necessary to protect us from a legal claim.

6. Access to other Websites

Our Site may include links to and from other websites of affiliates or other unaffiliated third parties. If you follow a link to any of these websites, please note that this Privacy Policy does not cover these websites. We are not responsible for the privacy practices of any third parties or the content of linked sites although we do encourage you to read the applicable privacy policies and terms and conditions of such parties or websites. This Privacy Policy only applies to how Shimano deals with your Personal Information, and it does not apply to any other company or any other company’s websites even if you access them via our Site. Please check those websites’ policies before you submit any Personal Information to them.

7. SMS Terms and Conditions

If you use a mobile device to access pages of the Website optimized for mobile viewing, opt in to receive SMS (text messages) from Shimano (as/when available), or use a mobile application, the following additional terms and conditions (“Mobile Terms”) also apply to you. Your access to the Website via your mobile device or use of a mobile application confirms your agreement to these Mobile Terms, as well as the rest of the Terms of Use. By opting in, you agree to receive promotional and personalized marketing text messages (e.g., SMS and MMS) on your mobile device from Shimano, including text messages that may be sent using an automatic telephone dialing system, to the phone number you provided when signing up or any other phone number that you designate. These messages may be recurring or one-time messages. Message frequency varies. Shimano reserves the right to alter the frequency of messages sent at any time, to increase or decrease the total number of messages sent. Shimano also reserves the right to change the short code or phone number from which messages are sent, and we will notify you when we do so.

Your consent is not required as a condition of purchasing any goods or services from Shimano. You can opt out at any time and for any reason by following the provided instructions or by texting “STOP” to the number associated with the SMS message. You will receive one further message confirming you are unsubscribed. You acknowledge that our text message platform may not recognize and respond to unsubscribe requests that do not include the STOP keyword command and agree that Shimano and its service providers will have no liability for failing to honor such requests. If you unsubscribe from one of our text message programs, you may continue to receive text messages from Shimano through any other programs you have joined until you separately unsubscribe from those programs. If you wish to join again, you can opt in at any time. If you have any questions or require further assistance, you may respond “HELP” to the number associated with the SMS message. For more information, please contact us by emailing [legal@shimano.com] (please reference “Questions about SMS”).

By agreeing to receive SMS messages from Shimano, you certify that you are over 18 years of age and (a) you are the mobile account holder or (b) you have the account holder’s permission to enroll the designated mobile phone number and understand that message and data rates may apply. You agree that you are solely responsible for all message and data charges that apply to use of your mobile device to access the Website or use of a mobile application. All such charges are billed by and payable to your mobile service provider. Not all mobile devices or handsets may be supported, and our messages may not be deliverable in all areas. Please contact your participating mobile service provider for pricing plans, participation status and details. Shimano, its service providers, and the mobile carriers are not liable for delivered or undelivered content. You understand that wireless through Wi-Fi or a participating mobile service provider may not always be available in all areas and may be affected by product, software, coverage or other service changes made by your mobile service provider or otherwise. Additional terms and conditions may apply to your use of a mobile application, based on the location and nature of use and the type of mobile device on which you install and use the mobile application.

8. Protecting Children’s Privacy

We are strongly committed to protecting the safety and privacy of children who visit our Website. Our Website is not designed nor is it intended to be used by children under 13, and we do not knowingly collect Personal Information online from children under 13.

9. Your Privacy Rights and Choices

9.1 Your Legal Rights. Subject to certain exemptions, you may have some or all of the following rights in relation to the Personal Information we hold about you:

• Right of Access. You have the right to access the Personal Information we hold about you and to receive a general account of our uses of that Personal Information. Upon receipt of a written request from you, we will provide you with a copy of your Personal Information, although in certain limited circumstances, we may not be able to make all relevant Personal Information available to you, for example, where that Personal Information also relates to another individual. In such circumstances, we will, upon request, provide you with the reasons for such refusal. We will try to deal with all requests for access of Personal Information in a timely manner. There is no pre-set limit for how many requests for access you can make in a year, but we may charge you a reasonable fee for access requests that require significant time and resources to manage where permitted under applicable laws.

• Right to Rectification. If the Personal Information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. Where appropriate, such amended Personal Information will be provided to the parties to whom we are authorized to disclose your Personal Information. We will try to deal with all requests for rectification of Personal Information in a timely manner.

• Right to Personal Information portability. You may have the right, in certain circumstances, to obtain Personal Information you have provided us with in a structured, commonly used, and machine-readable format and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

• Control Cookies and Similar Technologies. In addition to the opt-out rights described in this Privacy Policy, you may be provided with additional tools to control cookies and similar tracking technologies, such as a consent management tool or preference center.

• Request to Withdraw Consent: Where we process your Personal Information based on consent, you have the right to withdraw your consent at any time, subject to contractual and legal restrictions, and reasonable notice.

• Right to Complain: You have the right to contact us with any complaints or concerns about our practices with respect to the handling of Personal Information.

10. Privacy Notice for United States Residents

This Privacy Notice for United States Residents (“US Notice”) supplements our Privacy Policy.

This US Notice is for individuals residing in certain US states and is designed to help you better understand how we collect, use, and disclose your Personal Information and, depending on how you use our Services and where you reside, how to exercise available rights under various applicable privacy laws in the US, such as the California Consumer Privacy Act, the Colorado Privacy Act, the Connecticut Act Concerning Personal Information Privacy and Online Monitoring, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act (collectively, the “US Privacy Laws”).

10.1 What information we collect and share about you.

To provide our Services to you, we must process information about you, including Personal Information. We do not “sell” your Personal Information as that term is defined under US Privacy Laws.

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). See What Personal Information does Shimano Collect? For information on the Personal Information we have collected in the past 12 months.

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information for us to respond to requests for information or to fulfill orders for our products.

• To provide you with information, products or Services that you request from us.

• To improve our website and present its contents to you.

• For testing, research, analysis and product development.

• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• As described to you when collecting your Personal Information or as otherwise set forth in applicable law.

• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

10.2 Sharing Personal Information

We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter an agreement that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

10.3 Your Privacy Rights and Choices

Certain states have enacted laws or regulations giving consumers specific rights regarding their Personal Information. This section describes your rights and explains how to exercise those rights. Subject to certain exceptions, you have the following rights with respect to your Personal Information:

• To request that Shimano disclose what Personal Information it has collected, used, or disclosed, over the 12-month period preceding Shimano’s receipt of such a request;

• To request that Shimano disclose whether any of your information was sold or shared with third parties, to whom such information was sold or shared, and the business purpose for selling or sharing the information;

• To request that any inaccurate or incomplete Personal Information maintained by Shimano be corrected or supplemented; and

• To request deletion of your Personal Information maintained by Shimano.

All these rights are subject to certain conditions and exemptions. For example, Shimano will not be obligated to delete your Personal Information if we need to retain it to protect ourselves in the event of a legal claim.

10.4 Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• Debug products to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another r18ight provided for by law.

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may render impossible or seriously impair the achievement of the research, if you previously provided informed consent.

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

• Comply with a legal obligation.

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

10.5 Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by: Emailing the verifiable consumer request to legal@shimano.com. Only you, or a person appropriately authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

10.6 Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

10.7 Non-Discrimination

We will not discriminate against you for exercising any of your rights. Unless permitted by law, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

10.8 Authorized Agents

You may designate an authorized agent to exercise your rights on your behalf. If you use an authorized agent to exercise your rights, we will need proof that you have authorized the agent to act on your behalf.

11. Policies for Residents of EEA, UK and Switzerland

In addition to the other policies described in this Privacy Policy, residents of the EEA, the UK and Switzerland are afforded the following additional rights and protections as required by the European Union General Data Protection Regulation (“GDPR”), and UK and Swiss data protection laws. The additional rights and protections set forth in this section of this Privacy Policy apply only to residents of the EEA, the UK and Switzerland. For ease of reference, when we refer to GDPR in this section, we are referring to the UK and Swiss data protection laws, as well as the GDPR. For the purposes of this the GDPR, Shimano is a “Controller” which means Shimano determines the purposes for which, and the way, any Personal Information is Processed and used in its business.

This Notice describes the manner in which Shimano protects and processes (personal) data concerning European residents obtained through Shimano’s websites (collectively, the “Websites”).

11.1 Shimano’s approach to the protection and processing of personal data concerning European residents can be summarized as follows:

(1) Either Shimano or Shimano Europe B.V. is the Controller within the meaning of the European General Data Protection Regulation (“GDPR”) for the handling of Personal Information concerning European residents obtained through the Website(s) in compliance with the obligations set forth by relevant data protection law such as the GDPR, as well as this privacy policy. Which entity is the controller depends on the Website you are visiting. Moreover, depending on the processing activity, other companies within Shimano may be joint controller(s). Please contact us at http://fishshopcanada.shimano.com/contact-us, if you wish to obtain more information.

(2) Shimano will acquire Personal Information by lawful and fair means.

(3) Shimano will utilize Personal Information upon making clear the purpose of utilization and will only use Personal Information within the scope of the purpose.

(4) Shimano will not provide acquired Personal Information to a third party, except in cases in described in this privacy policy or the cookie policy.

(5) Shimano will appropriately manage Personal Information to secure its accuracy and will also take reasonable safety measures to prevent leakage, loss, damage, etc. of Personal Information.

(6) Shimano will manage Personal Information appropriately and take reasonable safety measures when Personal Information is utilized internally within the group or by third parties within the scope of its purpose of utilization or if Personal Information handling is outsourced.

(7) Shimano will announce the procedures regarding inquiries and requests for disclosure of Personal Information that Shimano possesses and will respond promptly and sincerely to such requests. If you accidentally send your inquiry or request to the wrong group company of Shimano, we will take care that such inquiry or request will be redirected to the correct group company.

(8) In order to implement the policy items, Shimano has assigned a privacy department, which can be reached at privacy@shimano-eu.com.

(9) Shimano will continuously revise and improve its Personal Information management system and structure to effectively protect Personal Information in accordance with future changes in laws or circumstances.

11.2 Definitions

The following additional definitions apply to this Section of the Privacy Policy:

“Processor” means any Person Processing Personal Information.

“Person” means a natural person, corporation, association, organization, partnership, or other legal entity.

“Process” or “Processing” is any activity that involves use of the Personal Information. It includes, without limitation, obtaining, recording or holding the Personal Information, or carrying out any operation or set of operations on the Personal Information including organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring Personal Information to third parties.

11.3 The legal basis for Processing your Personal Information

In order to comply with the GDPR, we are required to set out the legal basis for the processing of your Personal Information to comply with the GDPR, we are required to set out the legal basis for the Processing of your Personal Information. In accordance with the purposes for which we collect and use your Personal Information, as set out above, the legal basis for Processing your Personal Information will be one of the following:

• our own legitimate business interests, or the legitimate business interests of our third party partners, promoters, affiliates, distributors, suppliers, vendors, and subcontractors, such as, for example, providing direct marketing to our customers of our products and Services that we think would be of interest, permitting prospective employees to search and apply for job opportunities, handling inquiries from our promoters, affiliates, distributors, vendors, and customers, or other instances where we have carried out a legitimate interests assessment and have established an existing legitimate interest;

• the performance of a contract that we have in place with you;

• your consent where appropriate; or

• compliance with our legal obligations, including meeting national security or law enforcement requirements.

11.4 Where we store your Personal Information

The data that we collect from you is stored on our servers or on servers provided by cloud service providers. By submitting your Personal Information, you agree to this transfer, storing, and Processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

The transmission of information via the Internet is not completely secure. Although we take reasonable steps to protect your Personal Information, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

11.5 How long we store your Personal Information

In some cases, there is a legal requirement to keep Personal Information for a minimum period of time. Except in those circumstances, we do not keep your Personal Information for any longer than is necessary for the purposes for which the Personal Information was collected or for which it is to be further Processed.

11.6 Your rights with respect to your Personal Information

Subject to certain exceptions, you have the following rights with respect to your Personal Information:

• To receive or access a copy of the Personal Information that we hold about you;

• To request that any inaccurate or incomplete Personal Information be corrected or supplemented;

• To have your Personal Information erased, unless we have a legitimate reason to retain the Personal Information (such as if we are required to do so for legal reasons); and

• To ask us not to Process your Personal Information for a particular purpose, including for marketing.

All these rights are subject to certain conditions and exemptions. For example, Shimano will not be obligated to erase your Personal Information if we need to retain it to protect ourselves in the event of a legal claim.

To exercise any of these rights, please submit a written request to us using the contact information set forth below. Shimano reserves the right to charge a fee in dealing with such a request as permitted by applicable law and regulations. You may also opt out of receiving additional marketing information by using the unsubscribe feature in any marketing email we send you.

12. Retention of Personal Information

We retain Personal Information for as long as we have an ongoing business need to do so (e.g., to provide our Services to you, to comply with applicable legal, tax, or accounting requirements, for security and fraud detection or prevention, or in connection with backup or disaster recovery processes), unless a different retention period is permitted or required by applicable law.

The criteria used to determine our retention periods include the following:

· The length of time we have an ongoing relationship with you and provide our Services to you (for example, for as long as you have an account with us or keep using our Services);

· Whether you modify or delete your information through your accounts;

· Whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of your transactions for a certain period of time); or

· Whether retention is advisable considering our legal position (such as regarding the enforcement of our agreements, the resolution of disputes, the applicable statutes of limitations, litigation, or regulatory investigation).

13. Conditions of use and changes to our privacy policy

If you choose to receive our Services or visit our Website, any dispute over privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages, resolution of disputes, and application of the law of the Province of Ontario, Canada. If you have any concern about our privacy practices, please contact us with a thorough description, and we will try to resolve it. As our business changes, our Privacy Policy and Terms of Use may change also. We may, when we believe it is warranted, e-mail periodic reminders of our notices and conditions, but you should check our Website frequently to see recent changes. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.

14. Contacting us

This Website is owned and operated by Shimano. If you have any questions or suggestions with respect to this Privacy Policy or our privacy practices, please contact us at http://fishshopcanada.shimano.com/contact-us or you can contact us by mail at:

Shimano Canada Ltd.

427 Pido Road, Peterborough, Ontario K9J 6X7 Canada

Attention: Shimano Canada Ltd. Privacy Officer/Legal Department